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Former Spouse Cannot Seek Modification of Divorce Agreement in Rhode Island Federal Court


A federal magistrate judge in Rhode Island has ruled that a former spouse cannot file suit in federal court to seek a modification of her divorce agreement. Federal Magistrate Judge Patricia Sullivan ruled that the former spouse’s complaint, “boiled to its essence,” sought to modify the parties’ marital settlement agreement by changing the alimony provisions “potentially to a lifetime alimony award.” This, the Court found, was not permitted because federal courts have no jurisdiction over domestic relations decrees issued by state courts. The Court’s decision follows closely on the heels of a similar decision from the federal First Circuit Court of Appeals in Boston, which found that federal courts must look past the plaintiff’s characterization of their complaint as a federal action. Instead, federal courts are instructed to look to the substance of what the plaintiff is actually requesting and determine if, in fact, the plaintiff is challenging a domestic relations decree. Magistrate Judge Sullivan found that such was the case with the plaintiff’s complaint and dismissed her action for lack of federal jurisdiction. The case underscores that parties who are dissatisfied with their divorce settlement cannot resort to the federal courts to change the terms of their settlement.

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